20210108Application.pdf

Ronald L. Williams,ISB #3034
Williams Bradbury, P.C.
802 W. Bannock Street
Suite LP 100
Boise, lD 83702
[phone]
ron@williamsbradbury. com
," .:-'-'i',jr;.-I tr LiJ
:;,:: l:;ii -S Iiff li: Ia
:.-1- i, ::ll .i"1'i .i;,,:,,ri,--il0l,
Ch6rie R. Kiser
Angela F. Collins
Cahill Gordon & Reindel lr-p
1990 K Street, N.W., Suite 950
Washington, D.C. 20006
202-862-8900 (telephone)
212-269 -5 420 (facsimile)
[e-mail]
[e-mail]
Before the
IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of
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Application of Cable One VoIP LLC
for Designation as an Eligible
Telecommunications Carrier in the State of
Idaho to Receive Rural Digital Opportunity
Fund (Auction 904) Support for Voice and
Broadband Services and to Receive Federal
Lifeline Support
CaseNo.( A8-T- Q ret
APPLICATION
APPLICATION FOR DESIGNATION AS AI\
ELIGIBLE TELECOMMUNICATIONS CARRIER IN TIIE STATE OF IDAHO TO
RECETVE RITRAL DTGTTAL OPPORTUNTTY FUI\D (AUCTION 904)
SUPPORT FOR VOICE AI\iD BROADBAND SERVICES
A}TD TO RECETVE FEDERAL LIFELINE SUPPORT
Cable One VoIP LLC (the "Company"), by its attomeys, and pursuant to Section
zla@)Q)t of the federal Communications Act of 1934, as amended (the "federal Act"), the rules
I
47 U.S.C. $ 2la(eX2).
and regulations of the Federal Communications Commission ("FCC"),2 Idaho statutes,3 and the
requirements set forth in Idaho Public Utilities Commission ("Commission") Order No. 29841,4
hereby submits this Application for Designation as an Eligible Telecommunications Carrier
("ETC"). The Company seeks ETC designation to receive (l) Rural Digital Opportunity Fund
1':RDOF"; support for the provision of voice and broadband services in certain Census Block
Groups and (2) federal Lifeline-only support in other geographic areas of Idaho (collectively, the
"Designated Service Area" as set forth in EliblLD.
The Company's parent, Cable One, Inc. ("Cable One"), was a member of a consortium
that was selected as a winning bidder in the FCC's RDOF auction (Auction 904). The
Company's receipt of RDOF funding is conditioned upon the Company obtaining designation as
an ETC in the RDOF portions of the Designated Service Area, and providing evidence of such
designation to the FCC no later than Jvne 7,2021. [n addition to seeking ETC designation for
purposes of RDOF funding, entities also may seek Lifeline-only ETC designation in areas not
eligible for high-cost support for the limited purpose of becoming eligible to receive Lifeline
support (although recognizing the ETC will be obligated to provide Lifeline services throughout
the entire designated area).s
z 47 C.F.R. $$ 54.201,54.202; see also AU Docket No. 20-34, et al., Rural Digital Opportunity Fund Phase
I Auction (Auction 904) Closes; Winning Bidders Announced; FCC Form 683 Due January 29, 202 1; DA 20-1422
(rel. Dec. 7, 2020) ("Public Notice"); Lifeline and Link Up Reform and Modernization; et al., 27 FCC Rcd 6656
(2012) ("Lifeline Reform Ordei').
3 Idaho Stat. g 62-6loD.
a Case No. WST-T-05-1, The Application of WTIC Holding Co., Inc. dba Cellular-One Seeking Designation
as an Eligible Telecommunications Carrier that may Receive Federal Universal Sewice Support, Order No. 29841
(Aug. 4, 2005) (*ETC Ordei').
s Public Notice at t.72; see also Wireline Competition Bureau Seeks Comment on Petitions for Designation
as an Eligible Telecommunications Canierfor the Purpose of Becoming Eligible to Receive Connect Ameica Fund
Phase II Auction Support,33 FCC Rcd 9764 (2018) ("Recipients of high-cost support, including recipients of CAF
support awarded pursuant to Auction 903, must offer the Lifeline discount on all qualiffing services in areas where
an ETC receives high cost suppoft, deploy a network capable of delivering service that meets the Lifeline program's
minimum service standards, and commercially offer such service pursuant to its high-cost obligation.").
2
As demonstated herein, the Company meets all the statutory and regulatory requirements
for designation as an ETC in the State of Idaho. Accordingly, the Company respectfully requests
the Commission grant it ETC status in the Designated Service Area on an expedited basis prior
to the June 7, 202lFCC deadline.
In support of this Application, the Company states as follows:
BACKGROT]I\ID
1. The Company is a Delaware limited liability company with a principal place of
business located at2l0 E. Earll Drive, Phoenix, Arizona 85012. The Company is registered with
the Idaho Secretary of State to conduct business in the state as shown in Exhibit 2. The
Company will operate under the DBA name of "Sparklight" in Idaho, which also has been
registered with the Idaho Secretary of State as reflected in Exhibit 2. Attached as p4[![!!] is a
current list of the Company's officers, along with relevant biographical information.
2. The Company currently offers interconnected Voice over lnternet Protocol
("VoIP") services in the state of Arizona. The Company has never been denied ETC designation
by any state commission or by the FCC.
3. The Company is a wholly owned subsidiary of Cable One, a publicly traded
Delaware corporation (NYSE: CABO), and Cable One serves as the sole member of the
Company. Cable One and its subsidiaries provide cable/video, lnternet access, broadband, and
voice services in 21 states, including Idaho.6 Other subsidiaries of Cable One also hold ETC
designation in the states of Illinois, Missouri, and Oklahoma.
4. In January 2020, the FCC adopted the framework and rules for Phase I of the
RDOF auction (Auction 904) to connect millions of rural homes and small businesses to fxed
6 See, e.g., Case No. GNR-T-ZD-II, Cable One, Inc.'s Application for a 2019 Irwestment Tax Credit for
Installing Qualifiing Broadband Equipment, Order No. 347 58 (Aug. 21, 2020).
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high-speed broadband networks.T The FCC designed Phase I of the auction to award up to $16
billion over 10 years to service providers that commit to offer voice and broadband services to
fixed locations in eligible unserved high-cost cexrsus block groups. The framework for the
RDOF builds upon the FCC's successful Connect America Fund Phase II (CAF-ID auction that
was completed in 2018.8
5. The Company's parent, Cable One, participated in Auction 904 as a member of
the Wisper-CABO 904 Consortium (the "Consortium"). On December 7,2020, the FCC issued
the Public Notice announcing the results of Auction 904, and the Consortium was the winning
bidder in numerous states, including Idaho.e Pursuant to the FCC's process for distributing
winning bids among related entities,lo the Consortium assigned Cable One (the parent of the
Company) as the entity to receive RDOF support for the winning bids in the state of Idaho. The
Company will be designated as the entity to fulfiIIthe public interest obligations associated with
receiving RDOF support for Idaho in the long-form application (FCC Form 683) to be filed with
the FCC.
6. In addition to announcing the winning bidders, the FCC's Public Notice also
established several deadlines in connection with Auction 904. Relevant to this Application, the
FCC requires the Company to provide documentation to the FCC no later than 6:00pm Eastern
on June 7, 2021 showing the Company has been designated as a high-cost ETC for the census
block groups the Company will receive RDOF support.ll An officer of the Company also is
7 Rural Digital Opportunity Fund, et a1.,35 FCC Rcd 686 (2020) (RDOF Ordef').
8 The Commission conducted at least two ETC designation proceedings in connection with tho CAF-II
auction. See, e.g., Case Nos. NEW-T-I 8-0 I and VCS-T-I 8-01.
e PublicNotice,Attachment Aat29-30.
ro Public Noticeflfl 9-14.
tt Public Notice I 17 .
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required to certiff to the FCC on that date that the ETC designation covers all of the census
block groups for which the Company will receive RDOF support.
7. Pleadings, orders, notices and other correspondence filed in this matter should be
served upon:
Ronald Williams
Williams Bradbury, P.C.
802 W. Bannock Street
Suite LP 100
Boise, D 83702
[phone]
ron@williamsbradbury. com
Ch6rie R. Kiser
Angela F. Collins
Cahill Gordon & Reindel llp
1990 K Street, N.W., Suite 950
Washington, D.C. 20006
202 -862-8900 (telephone)
212-269 -5420 (facsimile)
[e-mail]
[e-mail]
The above-referenced individuals agree to receive all Commission notices and orders regarding
this proceeding via electronic mail.
INFORMATION REOUIRED UI\DER FCC RT]LES AI\D IDAHO LAW
8. Section zla@)Q) of the federal Act, the FCC's rules, Idaho Code $ 62-
6l0D(3)(a), and the Commission's ETC Order set forth certain requirements for ETC
designation in Idaho.12 The Company meets each of these requirements.
9. FCC Rule 54.201(c): FCC Rule 54.202(b): EZC Order. Appendix Section A.4.
An ETC applicant must demonstrate the ETC designation is consistent with the public interest,
convenience, and necessity, and in the case of an area served by a rural telephone company,
t2 47 U.S.C. $ 21a(e)(1);47 C.F.R. $$ 54.201, 54.202; Idaho Code $ 62-610D(3)(a); ETC Order, Appendix.
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demonstrate the public interest will be met by an additional designation. In evaluating the public
interest element, the Commission generally has considered two factors: (l) whether the entity
contributes to state assistance programs; and (2) whether the designation is sought for only part
of a rural telephone company's study area, thus leaving some (perhaps less profitable) customers
without service (i. e., cream skimming). I 3
10. Designation of the Company as an ETC will serve the public interest,
convenience, and necessity. ETC designation will permit the Company to use RDOF support to
offer voice and broadband services in the Designated Service Area, which consists of unserved,
high-cost areas of Idaho, and to provide Lifeline services to low-income consumers in other
areas of Idaho. The Company will invest in facilities and equipment in these areas. This
planned investment and deployment in the Designated Service Area will further the goals of the
Commission and the FCC by expanding the reach of digital connectivity to promote economic
growth in rural areas and ensure quality communications services are available at 'Just,
reasonable, and affordable rates."l4 As the FCC has observed, "an important goal of the [federal]
Act is to open local telecommunications markets to competition. Designation of competitive
ETCs promotes competition and benefits consumers in rural and high-cost areas by increasing
customer choice, innovative services, and new technologies."ls
11. The Company commits to participate in applicable Idaho assistance programs
upon approval and commencement of its business operations in Idaho. The Company's
participation in such Idaho programs also advances the public interest.
12. Finally, the Company is not engaged in "cream skimming." To the Company's
See, e. g., Order No. 33002 at 2-3 ; Order No . 33226 at 3.
47 u.S.C. $ 254(bxl).
Federal-State Joint Board on Universal Service, 16 FCC Rcd 48,n17 (2000).
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knowledge, there is no rural telephone company offering eligible broadband service in the RDOF
portions of the Designated Service Area because only "unserved" Census Block Groups were
included in Auction 904. ln addition, because the Company is requesting ETC designation for
entire census block groups, no cream skimming analysis is required.
13. FCC Rule 54.201(d): EZC Order. Aooendix Section A.1. An ETC applicant must
be a "common carrier" as defined by federal law.l6 The Company will provide broadband
Internet access service and voice service in the Designated Service Area. The Company will
provide voice service as either telecommunications service or VoIP service. As to customers and
locations in which the Company is awarded RDOF support or Lifeline-only customers, the
Company will provide its voice service on a common ca:rier basis.
14. FCC Rule 54.201(O(1): FCC Rule 54.201(j): EZC Order. Aooendix Section A.2.
An ETC applicant must demonstrate that it is capable of providing and will continuously provide
the supported services throughout the service area either by using its own facilities or a
combination of its own facilities and the resale of another carrier's services. The Company
certifies it will offer the services that are supported by the federal universal service support
mechanisms in the Designated Service Area either using its own facilities or a combination of its
own facilities and the resale of another carrier's services.lT Under current FCC rules, the two
services are supported by the federal universal service support mechanisms: (l) voice telephony
services; and (2) broadband Intemet access services.l8 Eligible voice telephony services must
provide voice grade access to the public switched telephone network ("PSTN") or its functional
equivalent, minutes of use for local service provided at no additional charge, access to
47 U.S.C. $ 153(ll).
47 C.F.R. g 5a.l0l(a); see also ETC Order, Appendix Section A.2
47 C.F.R. $ 5a.l0l(a).
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emergency 911 and enhanced 911 service in locations where implemented, and for qualifying
low-income consumers, toll limitation service.le Eligible broadband Internet access services
must provide the capability to transmit data to and receive data by wire or radio from all or
substantially all tnternet endpoints, including any capabilities that are incidental to and enable
the operation of the communications service, but excluding dial-up service.2o
15. The Company certifies that it will offer voice and broadband services in the
Designated Service Area that comply with the FCC's requirements. The Company's voice
offering will provide voice grade access to the PSTN, and will include unlimited local calling. In
addition, the Company's voice offering will provide consumers with access to 911 and enhanced
911 to the extent local governments have implemented such services. With respect to toll
limitation service, the FCC eliminated the requirement to provide toll limitation services if the
Lifeline offering provides a set amount of minutes that do not distinguish between toll and non-
toll calls.2r As explained below, the Company plans to offer unlimited voice calling within the
United States for a fixed monthly price in the Designated Service Area, and thus the Company is
not required to provide toll limitation service in connection with its Lifeline service offering.
16. Similarly, the Company's broadband Internet access service offering will provide
consumers with the capability to transmit data to and receive data from all or substantially all
Internet endpoints. The Company's broadband Internet access service offering will meet the
minimum service standards required by the FCC's rules,22 as well as the service standards
47 C.F.R. $ 54.101(aX1).
47 C.F.R. $ sa.l01(aX2).
Lifeline Refonn Order I 49
47 C.F.R. $ s4.408(bxl).
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applicable for the receipt of RDOF funding.23
17. The Company will use a combination of its own facilities and the facilities of
other providers to offer the supported services in the Designated Service Area. Under FCC rules,
facilities are the ETC's ooown" if the ETC has exclusive right to use the facilities to provide the
supported senrices or when service is provided by any affiliate within the holding company
structure.2a Furflrer, pursuant to FCC requirements, the Company will submit detailed
information to the FCC regarding the Company's intended technology and system design for the
provision of RDOF-funded services in the Designated Service Area, including network diagrams
certified by a professional engineer.25
18. FCC Rule 54.201(dX2): FCC Rule 54.405(b)-(d): EZC Order. Appendix Section
A.3. An ETC applicant must demonstrate that it will advertise the availability of its offering and
the charges therefore using media of general distribution. The Company will publicize the
availability of its voice and broadband service offerings throughout the Designated Service Area
using media of general distribution.26 The Company will use a combination of digital and
traditional media, such as the Internet, outbound email, outdoor advertising, radio advertising,
newspaper and magazine advertising, and direct marketing materials. The Company also will
rely on the marketing practices and advertising expertise of Cable One to advertise the
availability of its service offerings in the Designated Service Area.
19. In addition, with respect to Lifeline services, the Company will publicize the
availability of its Lifeline service offerings in the Designated Service Area in a manner
23 RDoF orderflfl 31, 33.
24 See, e.g., WCB Reminds Connect America Fund Phase II Auction Applicants of the Process for Obtaining a
Federal Designation as an Eligible Telecommunications Carrier,33 FCC Rcd 6696, m.23-24 (2018).
2s Public Noticellll 16-17.
26 47 c.F.R. $ s4.2ol(dx2).
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reasonably designed to reach those likely to qualifu for the service.2T Using easily understood
language, the Company will indicate on all materials describing its Lifeline service that (1) it is
a Lifeline service; Lifeline is a government assistance program; (3) the service is non-
transferable; (4) only eligible consumers may enroll in the program: and (5) the program is
limited to one discount per household.28 The Company also will disclose its name or its DBA
name on all materials describing the Lifeline service.2e
20. FCC Rule 54.201ft): FCC Rule 54.202(a)(4). An ETC applicant seeking to
provide Lifeline services must demonstrate it is financially and technically capable of providing
Lifeline service in compliance with the FCC's rules. The FCC has stated that the oorelevant
considerations" for satisfying this requirement would be whether the applicant previously offered
services to non-Lifeline consumers, how long the applicant has been in business, whether the
applicant intends to rely exclusively on universal service fund disbursements to operate, whether
the applicant receives funds from other sources, and whether the applicant has been subject to
enforcement action or ETC revocation proceedings in other states.3o
21. The Company is financially and technically capable of offering Lifeline services
in the Designated Service Area. As discussed above, the Company's parent and affiliates have
been offering services in Idaho and several other states for many years. Cable One also can
provide the Company with additional financial and technical support as needed, and the
27 47 c.F.R. $ 54.405(b).
28 47 C.F.R. $ 5a.405(c). For these purposes, the term "materials describing the service" includes all print,
audio, video, and web materials used to describe or enroll in the Lifeline service offering, including application and
certification forms. See id.
29 47 C.F.R. $ s4.40s(d).
Ldeline Reform Order \ 388.
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30
Company will utilize the same managernent and day-to-day operational personnel.3l The
Company currently provides voice services in Aizona, and thus will not rely exclusively on
universal service fund disbursements to operate. Finally, the Company has not been subject to
enforcement action or ETC revocation proceedings in any state.
22. ETC Order. AppendixSection A.5. The Commission's ETC Order requires an
ETC applicant seeking designation for "any part of tribal lands" to provide a copy of its
application to the affected tribal government or tribal regulatory authority, as applicable. A
portion of one Census Block Group in the RDOF portion of the Designated Service Area
(Census Block Group 160059400001 in Bannock County) overlaps with the Fort Hall
Reservation on which the Shoshone-Bannock Tribes are located. Thus, some of the locations
within that Census Block Group may be located on tribal land. Further, some of the Lifeline-
only service areas overlap with the Fort Hall Reservation. Accordingly, the Company certifies
that it will provide a copy of this Application to the Shoshone-Bannock Tribal Affomey's Office
via certified U.S. Mail and electronic mail within one (l) business day of the Application being
filed with the Commission.
23. FCC Rule 54.202(aXlI EZC Order. Aopendix Section B.1. An ETC applicant
must demonstrate its commitrnent and ability to provide the supported services. The Company
certifies that it will comply with the service requirements applicable to RDOF support and
Lifeline support in the Designated Service Area. The Company also certifies that it will: (a)
provide service on a timely basis to requesting customers within the Designated Service Area;
and (b) provide service within a reasonable period of time if the potential customer is within the
Designated Service Area, but outside the Company's existing network coverage if service can be
3r The Company's financial reporting is consolidated with its parent Cable One. Financial information
concerning Cable One can be found at: https://ir.cableone.net/corporate-profile/default.aspx.
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provided at a reasonable cost. The Company notes it must meet certain service milestones and
buildout requirements in the Designated Service Area as a condition of receiving RDOF
support.32
24. An ETC applicant also must submit network improvement plans at designated
intervals. A five-year network improvement plan is no longer necessary for entities seeking
Lifeline-only designation.33 Further, the FCC has waived the requirement for a winning bidder
in Auction 904 to file a five-year network improvement plan as part of the ETC designation
process.3a The Commission's ETC Order chose to require ETCs to submit a two-year network
improvement p1an.35 The Company respectfully requests the Commission waive its two-year
network improvement plan requirement as it has done for other ETC applicants based on similar
facts addressing such plan requirements.36
25. FCC Rtle 54.202@)(2\: ETC Order. Aoperdix SectionB.Z. An ETC applicant
must demonstrate that it can remain functional in emergency situations. The Company certifies
it will have the ability to remain functional in emergency situations in the Designated Service
Area. The Company has a reasonable amount of back-up power to ensure functionality without
an external power source, is able to re-route taffic around damaged facilities, and is capable of
managing traffic spikes resulting from emergency situations. Separate FCC rules also require the
32 RDOF Order I 45. For purposes of meeting the FCC's service milestones, a RDOF recipient will be
deemed to be commercially offering voice and/or broadband service to a location if it provides service to the
location or could provide service to the location within 10 business days upon request. See id. \ 54.
13 Lifeline Reform Orderl386.
34 Public Notice at n.7l (applying the same waivers previously applied to ETC desigrrations for the CAF-II
auction to ETC designations for Auction 904).
35 ETC order at8.
36 See, e.g., Order No. 34254 (*Staffdetermined that . . . a two-year network improvement and progress report
is not required due to the FCC's waiver of the five-year plan as part of its ETC designation process. . . . We agree
with Staff. Because the FCC waived the requirement for a winning bidder to file a five-year plan as part of the ETC
designation process, a network improvement plan is not required under Intermax's Application."); Order No. 34253
(same); Order No. 32723 (waivitgtwo-year network improvement plan requirement for Lifeline-only applicant).
t2
Company to implement certain back-up power requirements.3T In addition, as a subsidiary of
Cable One, the Company will be able to rely on Cable One's disaster recovery contingency plans
such as the use of diverse/alternate routing, electronics redundancy, redundant data centers,
geographically separated operations, and environmental controls for data and switching centers
to remain functional in an emergency situation.
26. FCC Rule 54.202(aX3): EZC Order. Appendix Section B.3. An ETC applicant
must certiff that it will comply with all applicable service quahty standards and consumer
protection rules.38 The Company certifies that it will comply with service qualrty standards and
consumer protection rules applicable to its provision of service in the Designated Service Area.
27. FCC Rule 54.202(aXfl: FCC Rule 54.202(aX6): EZC Order. Apoendix Section
8.4. The ETC Order requires an ETC applicant to provide a description of its local usage plans
and a description of the local usage plans of the incumbent local exchange carrier (*ILEC").
FCC rules also require Lifeline-only ETC applicants to provide information describing the terms
and conditions of voice telephony service and broadband Internet access service plans to be
offered to Lifeline subscribers. For Lifeline services, the FCC has determined that providers
may satisfy the obligation to provide local usage via service offerings that bundle local and long
distance minutes.3e
28. At this time, the Company plans to offer service plans that include high-speed
Internet access service and unlimited voice calling within the United States for a fixed monthly
price in the Designated Service Area. The Company also will offer standalone voice services as
37 47 c.F.R. $ 9.20.
38 The FCC has waived the requirement for a winning bidder in Auction 904 to demonstrate that it will satisft
consumer protection and service quality standards as part of the ETC designation process. See Public Notice at n.7l
(applying the same waivers previously applied to ETC designations for the CAF-II auction to ETC designations for
Auction 904).
3e Lifeline Reform Order\49.
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required by the FCC.40 The Company is conducting market research in the Designated Service
Area to determine what mix of services potential customers prefer. The Company has not yet
determined the specific details of its service offerings and associated rates to be offered in the
Designated Service Area. The Company will make services available based on customer
demand in each market. Further, the Company's pricing will be reasonably comparable to the
price of similar services in urban areas pursuant to FCC requirements.al By way of example, the
FCC's 2021 urbanaverage monthly rate is $33.73, and the reasonable comparability benchmark
for voice services, two standard deviations above the urban average, is $54.75.42 Accordingly,
each ETC providing fixed voice service must certiff to the FCC in luJy 2021that the pricing of
its basic residential voice services is no more than $54.75. The Company will offer calling plans
comparable to those offered by ILECs in the Designated Service Area.
29. ETC Order. Appetdix Section C. All ETCs requesting high-cost support must
provide certain information to the Commission on an annual basis. The Company certifies that it
will comply with all applicable annual reporting requirements of the Commission, including the
requirement to report information concerning: (l) outages; (2) unfulfilled service requests; (3)
complaints; (4) consumer protection and service quality standards; and (4) the Company's local
usage plans and ILEC local usage plans. As set forth above, the Company seeks waiver of the
two-year network improvement plan and progress report consistent with the Commission's
rulings for similarly situated applicants.
30. ETC Order. Aooendix SectionD. All ETCs must certify on an annual basis that
RDOF Orderl42.
RDOF Order\42.
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42 WC Docket No. 10-90, Wireline Competition Bureau and Ofiice of Econornics and Analytics Announce
Results of 2021 (Jrban Rate Survey for Fixed Voice and Broadband Sewices, Posting of Survey Data and
Explanatory Notes, and Required Minimum ()sage Allowance for Eligible Telecommunications Carriers, Public
Notice, DA 20-1049 (rel. Nov. 30,2020).
1,4
all federal high-cost support provided to the ETC will be used only for the provision,
maintenance, and upgrading of facilities and services for which the support was intended. The
Company certifies that, in accordance with 47 U.S.C. $ 254(e), it will use the RDOF support it
receives for the Designated Service Area only for the provision, maintenance, and upgrading of
facilities and services for which the support is intended.
31. FCC Rule 54.405(a). An ETC providing Lifeline services must make Lifeline
service available to qualiffing low-income consumers. The Company certifies that its Lifeline
service offering will conform to the definition of "Lifeline" in the FCC's rules.a3
32. FCC Rule 54.405(e). An ETC providing Lifeline services must implement certain
de-enrollment procedures for Lifeline customers. The Company certifies it will comply with the
FCC's de-enrollment procedures and will have general de-enrollment procedures in place for
Lifeline services. In accordance with FCC requirements, the Company will de-enroll Lifeline
customers for no longer qualifying for Lifeline service, for duplicative support, for non-usage,
for failure to re-certify, and when requested by the Lifeline customer.
33. FCC Rule 54.409: FCC Rule 54.410. The Company certifies that it will veriS the
eligibility of its Lifeline subscriber base in accordance with FCC rules. The Company also will
establish processes for ensuring Lifeline services are provided only to eligible customers,
including procedures for confirming consumer eligibility, enrolling eligible customers, re-
certifying eligibility at regular intervals, and recordkeeping.
43 47 c.F.R. g Sa.aol(a).
l5
CONCLUSION
WHEREFORE, for the forgoing reasons, the Company respectfully requests that the
Commission expeditiously designate it as an ETC for the provision of voice and broadband
services in the Designated Service Area.
Dated: January 8,202I Respectfully submitted,
CABLE ONE VOIP LLC
/s/ e.onald t-. Wtlliaws
Ronald L. Williams, ISB #3034
Williams Bradbury, P.C.
802 W. Bannock Street
Suite LP 100
Boise, ID 83702
[phone]
ron@williamsbradbury. com
Ch6rie R. Kiser
Angela F. Collins
Cahill Gordon & Reindel l.I.p
1990 K Steet, N.W., Suite 950
Washington, D.C. 20006
202 -862-8900 (telephone)
2 12 -269 5 420 (facsimile)
[e-mail]
[e-mail]
Its Attorneys
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VERIFICATION
I, Peter N. Witty, hereby state that I am the Vice President & Secretary of Cable One
VoIP LLC (the "Company"); that I am authorized to make this Verification on behalf of the
Company; tlrat the foregoing Application was prepared under my direction and zupervision; and
that the contents of the foregoing Application are true and correct to the best of my knowledge,
inforrration, and belief.
JI
Executed thi.I__ day of January 2021.
,v
PeterN. Witty
Vice President &
Cable One VoIP LLC
Exhibit I
Exhibit 2
Exhibit 3
EXHIBITS
Designated Service Area
Authorization to Conduct Business in Idaho and Evidence of DBA Name
Officers
EXTIIBIT 1
Designated Service Area
RDOF Service Areas
County
Ada
Ada
Ada
Ada
Ada
Ada
Ada
Ada
Ada
Ada
Ada
Ada
Ada
Ada
Ada
Ada
Ada
Ada
Bannock
Bannock
Bannock
Bannock
Bannock
Bannock
Bannock
Bannock
Bannock
Bannock
Bannock
Bannock
Bannock
Bannock
Bannock
Bannock
Bannock
Census Block Group
160010001002
160010001003
160010002023
160010008051
160010009001
160010009004
r60010010002
160010021001
160010023103
16001010201 l
160010102012
1600101022s1
16001010321 I
16001010331 l
160010103321
160010103351
16001010501 I
160010105031
160050002001
r60050002003
160050003001
160050003003
160050004001
160050005001
160050006002
1600s0007001
1600s0007002
1600s0008001
160050010003
16005001 l02l
16005001 1022
160050014001
160050015001
160050015002
160050015005
1
Countv
Bannock
Bannock
Bannock
Bannock
Bonneville
Bonneville
Bonneville
Canyon
Canyon
Jefferson
Nez Perce
Nez Perce
Nez Perce
Nez Perce
.Nez Perce
Payette
Payette
Payette
Payette
Twin Falls
Valley
Valley
Census Block Group
16005001601 I
r60050016012
r60050016032
r60059400001
160199701002
160199715001
1601997t5002
t60270219032
160270223002
160519604001
160699603002
160699604004
160699608002
160699608003
160699610001
160759601003
160759602003
160759604001
160759604003
160830006001
160859702002
1608s9703001
2
Additional Lifeline-Only Service Areas
(the following franchise areas may include the census block groups covered by the RDOF
service area listed above, but Lifeline-only service will be offered only in those areas not covered
by the RDOF service area)
Franchise Area
Garden
Boise
Ada
Shelley
Firth
Bingham
Bingham
Iona
Basalt
Blackfoot
Bonneville
Idaho Falls
Ririe
Ucon
Ammon
St. Anthony
Fremont
Teton
Rieby
Ririe
Sugar City
Rexburg
Madison
Rockford
Lewiston
Nez Perce
Chubbuck
Pocatello
Inkom
Bannock
American Falls
Salmon
Salmon
Burley
Burley
Burley
Countv
Ada
Ada
Ada
Bingham
Bingham
Bingham
Bingham
Borureville
Bingham
Bingham
Bonneville
Bonneville
Bonneville
Bonneville
Bonneville
Fremont
Fremont
Fremont
Jefferson
Jefferson
Madison
Madison
Madison
Bingham
Nez Perce
Nez Perce
Bannock
Bannock
Bannock
Bannock
Power
Lemhi
Salmon
Cassia
Minidoka
Cassia
J
Franchise Area
Hagerman
Wendell
Wendell
Gooding
Gooding
Jerome
Shoshone
Jerome
Heyburn
Minidoka
Rupert
Paul
Kimberly
Filer
Hansen
Twin Falls
Buhl
Twin Falls
Meridian
Boise
Star
Star
Kuna
Horseshoe Bend
Canyon
Greenleaf
Greenleaf
Nampa
Notus
Notus
Parma
Canyon
Middleton
Canyon
Purple Sage
Wilder
Caldwell
Cassia
Emmett
Owyhee
Countv
Gooding
Gooding
Gooding
Gooding
Gooding
Jerome
Lincoln
Jerome
Minidoka
Minidoka
Minidoka
Minidoka
Twin Falls
Twin Falls
Twin Falls
Twin Falls
Twin Falls
Twin Falls
Ada
Ada
Ada
Ada
Ada
Boise
Canyon
Canyon
Canyon
Canyon
Canyon
Canyon
Canyon
Canyon
Canyon
Canyon
Canyon
Canyon
Canyon
Cassia
Gem
Owyhee
4
New
New
Cascad€
McCall rfallo,y
5
Map of Desienated Service Area
(includes both RDOF census block groups and Lifeline-only areas)
Purple shows the current franchise areas served by Cable One, lnc. in Idaho, which will be the
geographic areas in which the Company will offer Lifeline-only service.
Green shows the boundaries of the census block groups awarded in the RDOF auction (Auction
e04).
6
H(HIBIT 2
Idaho Secretary of State Documentation
1
Office of the Secretary of State
State of ldaho
CERTIFICATE OF REGISTRATION
OF
CABLE ONE VOIP LLC
Filing Number: 4121333
l, LAWERENCE DENNEY, Secretary of State of the State of ldaho, hereby
certify that an application for Foreign Registration Statement, duly executed pursuant
to the provisions of the ldaho Uniform Business Organization Code, has been
received in this office and is found to conform to law.
ACCORDINGLY, by virtue of the authority vested in me by law, I issue this
Certificate of Registration to transact business in this State and attach hereto a
duplicate of the application for such certificate.
Dated: 7 January 2021
Lawerence Denney
Secretary of State
Processed by: Business Division
STATE OF IDAHO
Lawerence Denney I Secretary of State
Business Office
450 North 4th Street
PO Box 83720
Boise, lD 83720
Sparklight
210 E EARLL DR
PHOENIX, AZ 85012-2626
January 7,2021
Filing Acknowledgment
Please review the filing information below and notifo our office immediately of any discrepancies.
File #:
Filing Type:
Filing Date:
Status:
4121725
Assumed Business Name
01107120212:57 PM
Active-Current
Expiration Date:
lmage #:
Receipt #:
B0566-3828
000428900
Congratulations on the successful filing of your Certificate of Assumed Business Name for Sparktight in the State
of ldaho on the date shown above.
Mailing Address
210 E EARLL DR
PHOENIX, AZ 850',t2-2626
When conesponding with this office or submitting documents for filing, please refer to the file number given above
Denney
ldaho Secretary of State
Processed By: Business Division
Phone: [phone] " Email: [e-mail] * Website: sosbiz.idaho.gov
EXHIBIT 3
Officers of Cable One VoIP LLC
As of January I,2021, the following are the officers of Cable One VoIP LLC:
Julia M. Laulis. President & Chief Executive Officer
Laulis joined Cable One in 1999 as Director of Marketing-NW Division. In 2001, she was
named Vice President of Operations for the SW Division. In 2004, she became responsible for
starting Cable One's Phoenix Customer Care Center. Laulis was named Chief Operations Officer
in 2008, responsible for the company's three operation divisions and two call centers. In 2012,
Laulis was named Chief Operating Officer, adding sales, marketing, and technology to her
responsibilities. In 2015, Laulis was promoted to President and Chief Operating Officer of Cable
One. In 2017, she was named President and Chief Executive Officer and in 2018 she was named
Chair of the Board. Prior to joining Cable One, Laulis was with Jones Communications in the
Washington,DC area and Denver, where she served in various marketing managernent positions.
Laulis began her 35-year career in the cable industry with Hauser Communications. Laulis
graduated from Indiana University in Bloomington with a bachelor's degree in
Telecommunications. She attended the Woman in Cable Television Betsy Magness Leadership
Institute n 199811999 and graduated from the Program for Management Development at the
Harvard Business School in 2002. Cable FAX Magazine has named Laulis one of the Most
Powerful Women in Cable for the past l0 years mnning. Laulis currently serves on the boards of
The AES Corporation, Cablelabs, The Cable Center, and C-SPAN and is a trustee of the C-
S PAN Education Foundation.
Michael E. Bowker. Vice President
Mike Bowker is Chief Operating Officer for Cable One. He is responsible for overseeing Cable
One's daily operations, technology, and residential and business channels. Bowker joined Cable
One in 1999 as Advertising Regional Sales Manager. He is a member of the team that
successfully launched the commercial sales division and the residential inbound sales call center.
Bowker has been a Vice President of Cable One since 2005. He was named Vice President of
Sales in 2012 and was promoted to Senior Vice President, Chief Sales and Marketing Officer in
2014. Prior to joining Cable One, Bowker was with AT&T Media Services and TCI Cable,
where he served in various sales management positions. A native of Boise, Idaho, Bowker holds
a bachelor's degree in Communication from Boise State University and is a graduate of the
Stanford Executive Program at the Graduate School of Business at Stanford University. Bowker
currently serves as Vice Chairman of ACA - America's Communications Association.
Steven S. Cochran. Vice President
Steven Cochran is Senior Vice President and Chief Financial Officer at Cable One. He is
responsible for the areas of accounting, reporting, finance, and investor relations. A veteran of
the cable industry, Cochran spent 15 years at Wide Open West (WOW), a Denver-based cable
operator. During his tenure at WOW, Cochran held positions of increasing responsibility,
including Chief Financial Officer, Chief Operating Officer, and President and Chief Executive
Officer. Prior to WOW, Cochran was Senior Vice President and Chief Financial Officer at
Millennium Digital Media. Cochran holds a master's degree in accounting science and a
bachelor's degree in economics from the University of Illinois-Urbana Champaign
1
Jarrod L. Head. Vice President
Jarrod Head is Vice President of Engineering and Construction for Cable One. He is responsible
for outside plant engineering, design and construction. Before joining Cable One, Head served
as Vice President of Engineering & Technical Operations for Fidelity Communications and its
subsidiaries. Prior to that position, he served as Engineering Director for Fidelity, overseeing
Engineering and Network Operation teams to design, implement and support Fidelity's advanced
technology services. Head holds a bachelor's degree in Electrical Engineering from Missouri
University of Science and Technology.
Kenneth E. Johnson. Vice President
Ken Johnson is Senior Vice President of Technology Services at Cable One. He is responsible
for the strategic evolution of technology roadmaps related to products, as well as Information
Technology, and Network & Engineering. Before joining Cable One, Johnson served as Chief
Operating Officer and Chief Technology Officer for NewWave Communications. Prior to
NewWave, Johnson was Chief Technology Officer for SureWest Communications and Everest
Connections. Originally from Lenexa, Kansas, Johnson holds a bachelor's degree in Computer
and lnformation Sciences from Friends University. Johnson currently serves on the board of the
National Cable Television Cooperative.
Eric M. Lardv. Vice President & Assistant Secretarv
Eric Lardy is Senior Vice President of Operations and Integration for Cable One. He is
responsible for overseeing the company's day-to-day operations, acquisition integration and
long-term strategic operating plans. A more than 20-year veteran in the cable industry, Lardy
joined Cable One as a Pay-Per-View Manager in the Fargo, North Dakota cable system. He was
later promoted to Internet Business Manager, launching dial-up and high-speed broadband
services. Lardy relocated several times and held a variety of positions in Marketing, Operations,
and system General Management before being promoted to Director of New Products and
Service Projects in 2012. Ir 2014, he was named Vice President of Strategy and Finance. In
2017, he was promoted to Senior Vice President, adding oversight of human resources and
business intelligence to his responsibilities. Lardy holds bachelor's degrees in Marketing and
International Business from Minnesota State University and an MBA from Arizona State
University.
Ravmond L. Storck Jr.. Vice President & Treasurer
Ray Storck is Vice President of Finance and Treasurer for Cable One. He is responsible for all of
the company's accounting functions. Before joining Cable One, Storck served as Controller at
Kona Grill. Prior to that, Storck was Vice President/Controller and then Chief Financial Officer
for MicroAge. Following MicroAge, Storck spent 4 years at PetSmart where he served as Vice
President/Controller and then Vice President of Finance and Chief Accounting Officer. A native
of Iowa, Storck holds a bachelor's degree in Accounting from the University ofNorthem Iowa.
2
Peter N. Wittv. Vice President & Secretarv
Peter N. Witty is Senior Vice President, General Counsel and Secretary for Cable One. He is
responsible for overseeing the company's legal, regulatory and compliance functions. Witty has
more than 20 years of legal experience. Before joining Cable One, he served as General Counsel
and Secretary for Gas Technology Institute (GTI), a leading energy research, development and
training organization. Prior to GTI, Witty spent 10 years with Abbott Laboratories, serving in
various positions, including as Senior Counsel and Division Counsel. Witty also previously
practiced law as an associate at Latham & Watkins LLP and Ross & Hardies (now
McGuireWoods LLP). Witty holds a Juris Doctor from Notre Dame Law School and a
bachelor's degree in aerospace engineering from the University of Notre Dame. He is also a
graduate of the Stanford Executive Program at the Graduate School of Business at Stanford
University. Prior to attending law school, Witty was an officer and helicopter pilot in the 101st
Airborne Division (Air Assault), where he served during Operations Desert Shield/Desert Storm.
Additional information on the officers and directors of the Company's parent, Cable One, Inc.,
can be found at: https://ir.cableone.net/corporate-information/officers-directors/default.aspx.
3